461 U.S. 458 (1983) (U.S. Supreme Court)
Heckler v. Campbell is a foundational administrative law and Social Security decision that validates an agency's use of generally applicable, rule-based guidelines to resolve recurring factual issues in individual adjudications.
May the Secretary of Health and Human Services rely on medical-vocational guidelines, promulgated by rule, to establish the existence of jobs in the national economy that claimants with particular capacities and vocational profiles can perform, without presenting individualized vocational expert testimony in each adjudication; and, if so, what limits apply to the use of those guidelines?
Agencies may use notice-and-comment rulemaking to resolve general, recurring factual issues and thereby guide and structure individual adjudications. In the Social Security context, the Secretary may rely on the medical-vocational guidelines to take administrative notice of the existence of jobs in the national economy for claimants whose exertional RFC and vocational factors match a rule in the grids. However, the agency must still make individualized findings establishing the claimant's RFC and vocational characteristics, and the grids are not controlling when nonexertional impairments significantly limit the occupational base; in such cases, the Secretary must produce other evidence (e.g., vocational testimony) to meet the step-five burden. Courts review whether the regulations are consistent with the statute, whether substantial evidence supports the individual findings, and whether the guidelines were properly applied.
Yes. The Secretary may rely on the medical-vocational guidelines, adopted through rulemaking, to satisfy the step-five burden of showing that work exists in the national economy for claimants with particular exertional capacities and vocational profiles. The Court reversed the Second Circuit's categorical prohibition on exclusive reliance on the grids and remanded for consideration of whether, on the specific record, the guidelines were properly applied—particularly in light of any nonexertional limitations.
Heckler v. Campbell is a bedrock case on the interplay between rulemaking and adjudication. It authorizes agencies to use legislative rules to fix general factual predicates and streamline case-by-case decision-making while preserving the need for individualized findings where claimant-specific facts or nonexertional limitations matter. For Social Security practice, the case validates the medical-vocational grids as a primary step-five tool and clarifies that vocational expert testimony is not invariably required. For administrative law more broadly, it exemplifies permissible reliance on administrative notice of legislative facts and foreshadows Chevron-era deference to reasonable agency policy choices implemented through rulemaking.